20210817Staff 1-11 to INT.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
nr-4 I . nJ- '- irt iir- ii'UU
Street Address for Express Mail:
1I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS
COMPANY'S APPLICATION FOR
DETERMINATION OF 2O2O ENERGY
EFFICIENCY EXPENSES AS PRUDENTLY
INCURRED
CASE NO. INT-G.21-03
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Intermountain Gas Company ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY, SEPTEMBER 7, 2021.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it, or any person
acting on its behall may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY
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I AUGUST 17,2021
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO 1: Please provide a list of all expenses charged to the energy efficiency
tariff rider during 2020. Please include date, vendor, amount, a brief description of the expense,
and the account to which the expenses were booked. Please separate all expenses by program so
that the expenditures provided reconcile with the amounts listed in the Company's Annual
Report. Please also identifu whether each expense is an incentive payment, purchased service,
labor/administrative, materials and equipment, or other expense. Please provide the requested
information in Excel format with all formulas intact and enabled.
REQUEST NO. 2: Please provide copies of all internal audit reports referencing any of
the Company's energy efficiency expenses and processes for 2020 and202l, to date. If no
reports were issued, please provide the date and scope of each audit and all internal auditor
workpapers.
REQUEST NO.3: Please provide a current organizational chart showing all MDU,
Intermountain Gas, and contract employees by title and name who charge time to the energy
efficiency tariff rider. Please include complete job descriptions, required qualifications, salary
ranges, bonus opportunities, and total compensation ranges, including benefits, for all employees
identified in this request.
REQUEST NO. 4: Please provide a timeline of the Company's Full Time Equivalent
("FTE") positions for 2019 through 2021 to date, showing a month-by-month comparison of
FTEs that charge time to the energy efficiency tariff rider.
REQUEST NO. 5: Please provide monthly balances for the energy efficiency tariff rider
balance from January 2020 through June 2021. Please include monthly revenues, expenses, and
any interest calculations.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 AUGUST 17,2021
REQUEST NO. 6: The Company stated in its Application that it will address avoided
distribution costs following the filing of the202l IRP. When does the Company expect to
reconvene the Avoided Cost Subcommittee and address the distribution component of its
avoided cost calculation?
REQUEST NO. 7: Please provide the cost-effectiveness workpapers and calculations
for each energy effrciency program and measure in2020 in Excel format, with formulas intact
and enabled. Please include the workpapers and calculations for both the Simulation Analysis
and the Billing Analysis.
REQUEST NO. 8: On page 6 of Supplement I :2020 Cost-Effectiveness, please explain
why the cost for the Utility Cost Test ("UCT") is different between the Simulation Analysis and
Billing Analysis for each measure. Please provide a reconciliation of the UCT cost between the
Simulation Analysis and Billing Analysis for the Whole Home and Tankless Water heater
measures.
REQUEST NO.9: Please describe how the Company is leveraging the market
transformation work of the North American Natural Gas Heat Pump Collaborative
("Collaborative") to promote energy efficiency in the Company's service territory. Please
include examples of projects, demonstrations, energy efficiency programs, or collaborations of
work or future planned work since the Company has joined the Collaborative in20l9.
REQUEST NO. l0: Of the 229 tankless water heater rebates administeredin2020,
please provide a breakdown of the rebates administered between new construction, non-
operational equipment replacements, and operational equipment replacements.
REQUEST NO. l1: Of the 2,744 furnace rebates administeredin2D2}, please provide a
breakdown of the rebates administered between new construction, non-operational equipment
replacements, and operational equipment replacements.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 AUGUST I7,2O2I
DATED at Boise,Idaho, *"\lb*rof August 2021.
\
Deputy Attorney General
i:umiso:prodreq/ing2l.3dhblkkjt prod req I
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 4 AUGUST I7,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17th DAY OF AUGUST 202I,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO INTf,RMOIINTAIN GAS COMPAN-Y, IN CASE
NO. INT-G-21.03, BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
LORI BLATTNER
DIR _ REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
PRESTON N CARTER
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-MAIL .com
harmonywright@ eivenspursley.com
CERTIFICATE OF SERVICE